Provision record
Roblox · Roblox Privacy and Cookie Policy · View original document ↗

Behavioral Advertising and Cross-Context Data Sharing

High severity High confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Roblox uses your behavioral data and works with advertising partners who use cookies, pixels, and SDKs to serve you targeted ads based on your activity on Roblox and other websites. Users above the applicable age threshold are subject to this cross-context behavioral advertising.

This analysis describes what Roblox's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes third-party advertising partners to collect your behavioral and activity data across platforms using tracking technologies, which under California law constitutes 'sharing' personal information and triggers opt-out rights.

Recent Activity

This document changed recently

Medium May 1, 2026

The updated policy restricts personalized advertising based on age. Users under 18 will see only nonpersonalized ads on the platform, while users 18 and older may see personalized ads if they provide consent where required. The revised language also removes the previous statement that the platform collects personal information from under-13 accounts for advertising purposes, clarifying that such data is not used for marketing. Users 18 or older can control whether they see personalized ads through Roblox account settings.

View change record →
Medium Mar 8, 2026

The updated policy clarifies that parent email addresses constitute the only personal information collected from child accounts under COPPA, rather than listing persistent identifiers. The policy now states that personalized ads are not enabled until age 18, rather than leaving this ambiguous when a child turns 13. These clarifications affect how parents and children understand what data Roblox collects and when advertising becomes personalized; however, the underlying data practices do not appear to have changed operationally. The policy removed detailed descriptions of collection purposes (such as internal operations), which means parents now have less granular explanation of data uses, though stated practices remain.

View change record →

Clause Stability Stable

0
Changes
6
Months Monitored
May 12, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Change history

removed Jun 24, 2026

Removal reflects shift away from broad third-party behavioral targeting disclosure, likely replaced by more restrictive age-tiered advertising policies that prohibit such practices for minors.

View full change record →
modified May 14, 2026

Previous version had only high-level mention of 'Third-Party Advertising Data Sharing' with no excerpt; current version adds detailed explanation of behavioral advertising mechanisms, partner tracking technologies, and cross-context data collection methods.

View full change record →

Consumer impact (what this means for users)

Adult and teen users on Roblox may have their in-platform behavioral data and identifiers shared with advertising and analytics partners for targeted advertising; California residents have the right to opt out of this sharing under CCPA/CPRA.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Navigate to your Roblox account Privacy Settings at https://www.roblox.com/my/account#!/privacy and use the 'Do Not Sell or Share My Personal Information' option to opt out of behavioral advertising data sharing.

How other platforms handle this

Glassdoor Medium

We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We may use the personal information we collect to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We work with third-party advertising partners, including advertising networks, to display ads on our platform and other sites. These partners may use cookies, pixels, SDKs, and similar tracking technologies to collect information about your activities on our services and other websites to provide you targeted advertising based on your interests. We do not engage in cross-context behavioral advertising for users we know to be under the applicable age threshold.

Excerpt from Roblox's Privacy and Cookie Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages the CCPA and CPRA, which define 'sharing' personal information for cross-context behavioral advertising as a regulated activity requiring opt-out rights; the California Privacy Protection Agency (CPPA) and California Attorney …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011400
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
65526103181ac7fe55d4543ce0b351c34dc032fe69a8add53e6f30543ae9d94a
Analysis generated
May 12, 2026 09:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-011400
Captured: 2026-05-12 09:41:40 UTC
SHA-256: 65526103181ac7fe…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/provision/CA-P-011400/behavioral-advertising-and-cross-context-data-sharing/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Roblox's Behavioral Advertising and Cross-Context Data Sharing clause do?

This provision authorizes third-party advertising partners to collect your behavioral and activity data across platforms using tracking technologies, which under California law constitutes 'sharing' personal information and triggers opt-out rights.

How does this clause affect you?

Adult and teen users on Roblox may have their in-platform behavioral data and identifiers shared with advertising and analytics partners for targeted advertising; California residents have the right to opt out of this sharing under CCPA/CPRA.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.